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inland waterways

Subchapter M: The Clock is Ticking

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hile it’s been almost two years since the U.S. Coast Guard’s 46 CFR Subchapter M entered into effect and established an inspection regime for towing vessels, most existing vessels won’t have to meet its requirements until this summer—July 20, 2018. And it will actually be phased in over a six-year period for existing vessels. With a few exceptions, Subchapter M impacts nearly 6,000 vessels,

applying to towing vessels 26 feet in length and above and to those even smaller than 26 feet if they are used to move barges that carry oil or hazardous cargoes. Towing vessel companies that must comply with Subchapter M will have two options to meet the requirements: (1) They can schedule a traditional annual Coast Guard inspection; or (2) Use what many say is the more preferable option, the development of a Towing

Compiled by Marine Log Staff Safety Management System (TSMS). The TSMS describes the operator’s procedures for ensuring compliance with the applicable vessel and personnel requirements. TSMS compliance is verified by a Third Party Organization (TPO) and documented through the issuance of TSMS Certificates. Towing vessel operators would undergo audits and surveys from Coast Guard-approved TPOs. In accordance with 46 CFR 139.110, classification societies that are recognized and/ or authorized meet the requirements of a TPO. These classification societies are approved by regulation to perform certain work as a TPO without further Coast Guard approval. The class societies that may perform the functions of a TPO include: ABS, DNV GL, LR, BV, RINA, ClassNK, and IRS. ABS, for example, recently signed a contract with Cenac Marine Services, Houma, LA, to support the towing vessel operator’s efforts in complying with Subchapter M. “Tugboat owners and operators are urgently seeking and evaluating options for Subchapter M compliance,” says ABS Americas Division President Jamie Smith. “With the Certification of Inspection date rapidly approaching, ABS is guiding owners to find the right compliance solution – suited for

Coast Guard Approved Subchapter M Third Party Organizations (TPOs) (Non-class societies, approved IAW 46 CFR 139.115)

Cenac Marine

The following companies have been approved by the U.S. Coast Guard as Subchapter M Third Party Organizations (TPOs). They can audit Towing Safety Management Systems (TSMS), issue TSMS certificates to an owner or operator, survey towing vessels to verify compliance with Subchapter M, anad issue survey reports detailing the results of towing vessel surveys. American Global Maritime 11767 Katy Freeway, Suite 660 Houston, TX 77079 T: (281) 558-3690 www.globalmaritime.com/usa

Marine Compliance 7702 FM 1960 East, Suite 226 Humble, TX 77346 T: (281) 812-1095 www.marcomllc.com

Tompkins Consulting 2546F S. Arlington Mill Drive Arlington, VA 22206 T: (917) 559-9045 www.tompkins-consulting.com

Decatur Marine Audit & Survey 8619 Westwood Center Drive, 3rd FL Vienna, VA 22182 T: (703) 564-7563 decaturmarine.com

Quality Maritime Training 14603 Beach Blvd. Jacksonville, FL 32250 T: (904) 683-1985 www.qualitymaritimetraining.com

Towing Vessel Inspection Bureau 15201 East Freeway, Suite 213 Channelview, TX 77530 T: (832) 323-3992 www.thetvib.org

Meridian Global Consulting 812 Downtowner Blvd., Suiet A Mobile, AL 36609 T: (251) 345-6776 meridian.us/services

Sabine Surveyors 2424 Edenton Ave., Suite 620 Metairie, LA 70001 T: (504) 831-9100 sabinesurveyors.com

WaveCrest Offshore Solutions 21366 Provincial Blvd. Katy, TX 77450 T: (713) 302-6763 www.onewavecrest.com

March 2018 // Marine Log 15

Marine Log March 2018  
Marine Log March 2018